CFGI / U.S. Immigration / Our Advocacy / Policy Recommendations ACIP Submits Comments to USCIS on I-140 Interim Policy Memorandum 9/3/2010 U.S. Citizenship and Immigration Services Page ContentOn September 3, 2010, ACIP presented U.S. Citizenship and Immigration Services (USCIS) with written comments on the Interim Guidance Policy Memorandum titled “Evaluation of Evidentiary Criteria In Certain I-140 Petitions” (AFM Update AD-10-41), as part of the USCIS Policy Review Project. The memorandum lays out new guidelines to adjudicators for certain employment-based permanent residence petition types. ACIP finds the memorandum’s “Two-Prong Approach to Evaluate Evidence” too subjective to be included as part of the formal adjudication process, and believes it could lead to increasingly arbitrary and inconsistent adjudications. In the comments, ACIP also lays out several suggestions regarding types and evaluation of initial evidence.